Banker's Compliance Consulting Blog

Identify Theft Red Flags

Written by Kevin Edwards | Aug 8, 2025 8:47:41 PM

Each financial institution that offers or maintains covered accounts is required to develop and implement a written Identity Theft Prevention Program that is designed to detect, prevent and mitigate identity theft.  Appendix J to Part 334 states…the Program should include relevant Red Flags from the following categories, as appropriate

(1) Alerts, notifications, or other warnings received from consumer reporting agencies or service providers, such as fraud detection services;

(2) The presentation of suspicious documents;

(3) The presentation of suspicious personal identifying information, such as a suspicious address change;

(4) The unusual use of, or other suspicious activity related to, a covered account; and

(5) Notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the financial institution or creditor.

Supplement A to Appendix J also includes examples of Red Flags for each of these five categories.  A few examples include:

  • A fraud or active duty alert is included with a consumer report.
  • Documents provided for identification appear to have been altered or forged.

  • Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer's covered account.

Kevin explains more in the video.

 

Published 
2025/08/08